Subject: File No. 4-573
From: Dickson Cannon
Affiliation: Cannon Company

November 13, 2008

Mark to Market Accounting is perfectly fine when there is a market place to instantly liquidate the asset at market value such as NYSE or NASDAQ. In real estate, it takes a minimum of 60 days to sell a house if not 6 months. In commercial real estate, I have seen owners take 2-3 years to sell an asset. Also, just because the asset value is less doesn’t mean the loan will not be paid in full. If there is a 20% reduction in value then loans should be written down, but a borrower may make up the difference by selling other assets to avoid the tainted record of a foreclosure. Until the loan is due on real estate assets, no one knows what will happen to the loan. Marking it down prior to loans term is and has proven disastrous to the credit markets. Trouble now is if it lifted, what do you do now with Lehman and others who already went bankrupt? In my opinion, those that already went BK, would have eventually. Mark to Market forced it to happen much sooner creating the fear that has driven our economy off a cliff.

Dickson Cannon
Cannon Company